We are considering opening a new account on a privately held Canadian (Alberta) Corporation. The Certificate of Amalgamation was filed on 2011/12/01 with a corporate access number of 2016------. (We are assuming the 2016 is the expiration date.) We have been unable to find the corporate name or access number on the Canada.gc.ca website. However, there are several articles referencing this corporation on the internet (all good) so we know it is an existing corporation. Does anyone have a suggestion as to how we can verify and complete our CIP review. Thanks for any input.

Does anyone have a suggestion as to how we can verify and complete our CIP review.

Without knowing what your CIP requires you to do for foreign corporations, how can we answer this question.

Said differently, your CIP should address any account relationship you are considering. If it does not, you need to think about 1) revising your CIP via board action or 2) whether you should be opening an account for a customer with characteristics completely unfamiliar to your bank.

Remember: "They can't put it on the Internet if it isn't true!" Bonjour!

The principal of the Corportion is already a borrower as he has dual citizenship. We have a few real estate loans to him as an individual/guarantor. We just want to make sure the Canadian Corporation is in good standing and the documents he provided are accurate and we have done our due dilegence.

If you don't know how to do it, then you shouldn't be attempting it. What does this Canadian company needs with a US banking relationship and why are they bothering with a bank that does not specialize in international banking. Ding, ding, ding - first red flag.

Having an existing relationship with someone that has "dual citizenship" means nothing when it comes to BSA compliance. Con artists and people who successfully launder money go to great lengths to establish what looks like legitimate banking relationships.

I so disagree with your First Red Flag comment.
What is unusual about a Canadian having a US banking relationship?
They don't need an international bank to conduct business in the US.
Besides which, Comply Ofcr said he is an existing customer and a US person.

Wait... You've already obtained the formation documents for the entity? At that point I would say that you have already verified the identity of your customer.

Magic - There is a huge difference between banking an individual that is an NRA that is sitting in front of you and banking a foreign entity. They are entirely different animals when it comes to performing required due diligence and on going monitoring. If you have to ask how to do it, then that tells me you are not geared up to normally open these type of customer accounts. People that want to do illicit things through off-shore companies prey on these types of banks rather then going to banks that have an international banking department.

Say what you want, but I see it time and time again.

ACB - entity documents - if you don't normally open Canadian entity accounts, how do you even know the documents are legitimate or how to verify them as such? Hence the original questions. Just because a customer wants to open an account doesn't mean a bank should do it when you are not familiar with the verification processes.

Thanks for clarifying Randy. I guess I didn't read the OP carefully enough. That said, a little but of research online will usually get the information you need. I would try some of the links below, they may be helpful. MY FI opens business accounts for business entities established all over the world. It's been my experience that the legitimate ones are more than willing to explain where and how they are registered.


https://corporationscanada.ic.gc.ca/eic/site/cd-dgc.nsf/eng/cs02719.html

http://www.servicealberta.com/731.cfm

ABC,

I was in email contact with the first source you provided; however, they stated they cannot provide any information as the company is privately held. I'll give the second one a try.

We have deposit accounts for the principal of this company. This is not some "walk-in" customer that we don't know. We have dealt with him for many years. I'm simply looking for a means to demonstrate to our regulators that we did the appropriate due diligence on this particular entity.

ABC, you indicate you open accounts for entities all over the world. Is the due diligence centralized? Do you use a service to assist you with verifying that entities are legit? I don't expect that this will be something we do very often; however, I do expect that it might happen again and I would like to be able to respond to these requests.